Here we are at years end. A time often focused on assessing the years events & developments, ups and downs. For the winemaking world 2012 has already been marked as an incredible one in relation specifically to the grape harvest. (At least here in California) But what about in relation to compliance? What were the stories there? And what’s to come for wineries in 2013 that they’ll want to pay attention to for keeping on top of their compliance?
I’ll start off with the year end wrap up summary as far as TTB compliance. 2012 was a year where wineries continued to be given ways to avoid the TTB, so to speak. The updated allowable changes to wine labels came along in July which brought us a much broader range of common label changes than had ever been allowed before that do NOT require a new label approval submission. For more on this here’s a link w/full details: http://www.ttb.gov/labeling/allowable_revisions.shtml
The TTB also revamped its website in August this year, giving it a more “user friendly” look in part I’m sure designed to make commonly requested information easier to locate, thus attempting to cut down on phone calls or emails sent to them that continue to ask for the same sorts of information. I give the TTB a thumbs up for the website re-do, especially as someone who has watched it evolve over the past 15 years. I still find it to be one of the easiest government websites to navigate. (That’s saying a lot!) If you haven’t already seen it go take a look: http://www.ttb.gov/wine/index.shtml
The other government agency, the FDA also came back on our radar in 2012. The required registration of food facilities (which wineries are part of in their eyes) once started out as a one time registration. Then in 2012 the FDA changed that required registration to every two years. Now all wineries must have submitted their first of these registrations by December 31st. For more info on that here’s a link: http://www.fda.gov/Food/FoodSafety/FSMA/ucm314178.htm
2013: Your compliance looking forward
What can you expect in the way of TTB updates in 2013? Here again I think you can continue to expect to see them offer new ways of “avoiding” us.
One of those ways is via their now about 2 year old electronic filing system, Permits Online. This system for submitting permit applications and amendments has to date only been available for brand new permit filers but they continue to list on their website that it will soon be opened up to pre 2011 permit holders.
This will mean that all existing TTB bonded wineries (& other TTB permit holders) would be able to use this online system to make updates to their TTB permits that they currently have to go the snail mail, paper copy route. One of the major advantages I see to this system is that it sets up all of your TTB permit information easily accessible in one place- where you know that you & the TTB are on the same page. Here’s a link to their site for it if you haven’t seen it yet: http://www.ttb.gov/ponl/permits-online.shtml
One last suggestion I’ll offer you for getting off on the right foot with your 2013 compliance is to sign up for my upcoming free teleseminar, Guidance, Support & Ease with your Winemaking Compliance”.
I’ll be covering topics related to your ongoing day to day TTB compliance, and ways to simplify it so it takes you less time and much less hassle. What better way to start off your winemaking year?
Here’s a link to find out full details: http://winecompliancealliance.com/home/free-teleseminar-guidance-support-ease-for-your-winemaking-compliance